A rather controversial suggestion that attracted publicity. Even the BBC news website picked it up, for example (www.bbc.co.uk/news/uk-43429713). But there was something else that struck me about the Daily Mail report: its final sentence. It said: “The former model has teamed up with clothing company Become to create underwear for women going through the menopause.” In other words, the newspaper “reported” that the TV presenter was plugging a menopause-related clothing firm – and duly identified it. (The BBC report, meanwhile, said nothing about the clothing company.)

Thus we might understand why Ms McLeansaid something so outlandish to the newspaper: to publicise the clothing company, which ispresumably paying her.

But here my focus is the Daily Mail. The report risks undermining the newspaper’s editorial integrity. It wasn’t actually a report, but an ad. A hidden ad presented as editorial. How misleading and dishonest.

At date of publication Susie Coen, the reporter who wrote the article, hasn’t responded to a request for comment. As you can see, Ms Coen is “showbusiness” reporter.

The Responsible Gambling Strategy Board (RGSB) is an “independent expert body” whose “aim is to minimise gambling-related harm”. Funded by regulator the Gambling Commission, RGSBmeets “regularly”, and publishes the minutes for its meetings on its website – or at least says it does. In fact,there at date of publication the latest minutes are for the meeting on 18 July 2016! (screen shot in Figure 1).

Figure 1. RGSB board meetings and minutes: website at 9 March 2018

RGSB has two main functions. First, it sets the national responsible gambling strategy for the Gambling Commission. The expert advisers define the “research, education and treatment” required to deliver the strategy. Second, RGSB also “works closely” with GambleAware, the leading gambling charity (see previous post), thus ensuring implementation of the national responsible gambling strategy.

In response to my query why RGSB has failed to publish minutes for meetings after 18 July 2016, Sarah Webster of the RGSB secretariat said in an email last week: “The glitch was highlighted in the summer after website (sic) was updated by our IT manager, it was brought to our attention in January that there was still a problem with the website and we are working on a solution.”

The Gambling Commission yesterday (19 March 2018) published its eagerly awaited advice to support the government with its review of gaming machines and social responsibility measures. In its linked letter to the Secretary of State (for Digital, Culture, Media and Sport), the regulator rightly berates the gambling industry for making “insufficient progress” in relation to the objectives of the national responsible gambling strategy.

Yetit’s not just the gambling industry failing to make sufficient progress: the body that sets the national responsible gambling strategy is, too – at least in publishing the minutes for its meetings. This failure undermines public trust and confidence in both RGSB and the national responsible gambling strategy. Further, RGSB‘s response is hardly reassuring: it’s vague and lacks a sense of urgency.

On 20 February 2018, Campaign reported on its website that GambleAware, the leading gambling charity, has engaged the Incorporated Society of British Advertisers (ISBA), the trade body for UK advertisers, to help it select an advertising agency for a new £7m public awareness campaign about low-level gambling-related harm. This tie-up hasn’t received the attention it deserves – perhaps because the charity failed to publish on its website a press release(s) about it. Further, at date of publication searching the GambleAware website for “Incorporated Society of British Advertisers” or “ISBA” produces no hits. Here are four problems with GambleAware working with the self-styled “voice” of UK advertisers.

First, big gambling firms are members of ISBA, the list on its website shows. Thus ISBA isn’t independent from the gambling industry.

Second, the big gambling firms splash a lot on advertising. Several are in the top 100 advertisers by spend in UK national newspapers, for example (list on Newsworks website, for the year to September 2017). Then there’s the sector’s alarming arms race in advertising: marketing spend in the UK sports betting market has increased by a staggering “estimated 19% per annum in the last few years”, according to Paddy Power Betfair, the FTSE 100 firm, when announcing its 2017 preliminary results on 7 March 2018. Clearly, the battle for market share is fierce. Meanwhile, organisations that spend more on advertising also pay more for ISBA membership, the trade body told me in an email. (At date of publication its website doesn’t even reveal this.) So the big gambling firms must have significant influence over ISBA.

Third, ISBA is opaque, as its failure to disclose membership rates on its website indicates. When I queried this, Claudia King, “the powerhouse of the membership team”, said in an email: “Members who spend more on advertising will pay a higher fee as it’s based on their media spend. I’m afraid I can’t share any more information than that.” Its non-transparency and unaccountability are ironic given ISBA is loudly demanding transparency and accountability from the tech giants – Google and Facebook, in particular – as well as advertising agencies. ISBA’s 2018 annual conference, which took place last week on 6 March, was entitled “The Age of Accountability”.

Fourth, membership “supports your sectoral lobbying efforts” (screen shot in Figure 1). Thus the trade body explicitly identifies, and promotes, itself as a lobby group. Like any other sector, the gambling industry presumably uses ISBA for this purpose. Otherwise, why join? More accurately, why pay to join? GambleAware surely shouldn’t be involved with an organisation that lobbies for, and with, the gambling sector.

Gambling advertising is everywhere – including football shirts, notoriously. And it continues to rocket, as Paddy Power Betfair’s latest results last week show. The bookmaker reported that in 2017 its Paddy Power brand lost share in marketing spend in the UK sports betting market (15% in 2014 v 12% in 2017). Cue another hike in advertising spend: the firm will this year add around £20m to its worldwide £300m annual advertising budget. (These figures put into context GambleAware’s £7m campaign – and Paddy Power Betfair is just one gambling firm operating here, of course.) Yet many believe there’s already too much gambling advertising, and not just in the UK.

For many reasons, gambling advertising is a highly contentious issue. Nevertheless ISBA “champions advertising and promotes the freedom of commercial speech” (latest directors’ report, made up to 31 March 2017). Critically, it also supports “responsible” self-regulation by the advertising industry, and has a voice in that self-regulation. Thus ISBA influences the UK advertising codes, which are written by the Committee of Advertising Practice (CAP). The codes are in turn enforced by the advertising regulator, the Advertising Standards Authority (ASA).

In short, gambling advertising raises many questions, and ISBA has conflicted roles in and around it. The organisation is therefore conflicted in the ongoing debates, too. ISBA can’t act for both GambleAware and the gambling sector, if the charity is to maintain its independence and credibility (see 27 February 2017 post). The arrangement represents a fatal conflict of interest for the trade body for UK advertisers. Further, the lack of transparency and accountability only further undermine public trust and confidence in both GambleAware and ISBA.

What’s worse, it’s not even clear what ISBA is actually doing with, and for, GambleAware. A report on the Marketing Week website, a few days before the Campaign one, quotes Phil Smith, director general of ISBA, saying his organisation is working with the charity “to help plan and develop its new campaign” (screen shot in Figure 2). Rather more, then, than simply helping it select an advertising agency. Thus there’s an urgent need for clarity on ISBA’s activities with, and for, GambleAware.

Figure 2. Marketing Week website: ISBA is working with GambleAware “to help plan and develop its new campaign” at 10 March 2018

In a response to a request for comment, Abi Slater, director of communications, said in an email: “At ISBA we represent responsible advertisers. We believe our gambling members are absolutely right and proper to take responsibility for some of the issues around problem gambling. To be clear we and our members will have no influence on how this campaign is executed. ISBA’s only role is to ensure they have the best agency team to develop an effective campaign.” In her second message, Ms Slater decided to be more forthcoming about membership rates, after prompting: “I can confirm that fees start at around £5k and then are on a sliding scale based on Nielsen data. This is the information we give potential members when we discuss costs with them.” (Still not full disclosure, but an obvious improvement over what Ms King was prepared to divulge earlier.)